-6-
it would have resulted in $277,440.00 in additional
taxable income for Petitioner’s 1988 tax year.
(aa) Petitioner knowingly, willfully, and with
the intent to evade tax signed and caused to be filed
with the Service returns for his 1986 through 1990 tax
years that understated his tax liability for each year.
(ab) Petitioner reported a negative taxable
income of $234,345.00 on his return for his 1986 tax
year when he then and there well knew and believed that
the sale reported thereon should have been reported as
an installment sale with a taxable gain of $739,840.00,
which when combined with the other items of income and
expense on his return would have resulted in taxable
income of $805,495.00 for his 1986 tax year.
(ac) Petitioner reported a $234,775.00 net loss
carry forward on his return for his 1987 tax year and a
negative taxable income of $184,120.00 for that year
when he then and there well knew and believed that he
should not have reported any loss carry forward and
that he should have reported a positive taxable income
in the amount of $50,665.00.
(ad) Petitioner reported a $180,320.00 loss carry
forward on his return for his 1988 tax year and a
negative taxable income of $140,347.00 for that year
when he then and there well knew and believed that he
should not have reported any loss carry forward, that
he should have reported taxable installment sale income
of $277,440.00, and a positive taxable income in the
amount of $317,413.00.
(ae) Petitioner reported a $136,147.00 loss carry
forward on his return for his 1989 tax year and a
negative taxable income of $76,230.00 for that year
when he then and there well knew and believed that he
should not have reported any loss carry forward and
that he should have reported a positive taxable income
in the amount of $59,517.00.
(af) Petitioner reported a $72,230.00 loss carry
forward on his return for his 1990 tax year and a
taxable income of $21,833.00 for that year when he then
and there well knew and believed that he should not
have reported any loss carry forward and that he should
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